{"operation":"document","citation":"PHMSA-2017-0090","title":"National Fuel and Gas Supply Corporation — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2019-08-27","effective_on":"2019-08-27","summary":"PHMSA-2017-0090, issued 2019-08-27 for National Fuel and Gas Supply Corporation's transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0090.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0090.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0090","source_url":"https://www.regulations.gov/docket/PHMSA-2017-0090","body":"PHMSA pipeline special permit PHMSA-2017-0090. Operator: National Fuel and Gas Supply Corporation. System: Transmission. Issue date: 2019-08-27.\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSPECIAL PERMIT\nSpecial Permit Information:\nDocket Number:\nPHMSA-2017-0090\nRequested By:\nNational Fuel Gas Supply Corporation\nOperator ID#:\n13063\nOriginal Date Requested:\nJuly 28, 2017\nOriginal Issuance Date:\nAugust 27, 2019\nEffective Dates:\nAugust 27, 2019 to August 26, 2029\nCode Section(s):\n49 CFR 192.53, 192.55, 192.105, 192.107, 192.109, 192.111,\n192.113, 192.144, 192.149, 192.150, 192.327, 192.463, and\n192.619\nGrant of Special Permit:\nBy this order, subject to the terms and conditions set forth below, the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) Office of Pipeline Safety (OPS)' grants this special permit\nto National Fuel Gas Supply Corporation (NFG) waiving compliance from 49 Code of Federal\nRegulations (CFR)) 192.53, 192.55, 192.105, 192.107, 192.109, 192.111, 192.113, 192.144, 192.149,\n192.150, 192.327, 192.463, and 192.619 for one (1) pipeline segment totaling 5.8 miles of 6-inch\ndiameter FlexSteel pipe and components located in gas transmission class 1 and 2 locations on the\nFM120 Pipeline located in McKean and Elk Counties, Pennsylvania, as described below. This special\npermit is for usage of FlexSteel pipe and components in Class 1 and 2 locations inserted within a\n12.75-inch diameter casing pipe. FlexSteel is a type of flexible steel pipeline, which is not currently in\nuse in PHMSA-regulated interstate gas transmission pipelines.\nPurpose and Need:\nThis special permit grant is part of a modernization project which will allow NFG to use FlexSteel\n1 Throughout this special permit the usage of \"PHMSA\" or \"PHMSA OPS\" means the U.S. Department of Transportation's\nPipeline and Hazardous Materials Safety Administration Office of Pipeline Safety.\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 1 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 2>>>\n\npipe to replace a 12.75-inch diameter, 1950's vintage bare steel pipeline, known as the FM120\nPipeline. The new 6-inch diameter FlexSteel will be inserted through the existing 12.75-inch diameter\npipeline, which will require significant maintenance and repair to continue to operate in pressurized\nnatural gas service. Use of FlexSteel will significantly reduce excavation, earth disturbance, and other\nactivities associated with removal of the existing 12.75-inch diameter steel pipeline and installation of\na new steel pipeline into the right of way.\nThis special permit with conditions implemented by NFG will allow the use of FlexSteel pipe for this\nmodernization project. This special permit will allow NFG to replace approximately 5.84 miles of\nFM120 Pipeline (1950s vintage 12.75-inch diameter bare steel natural gas pipeline) through insertion\nof 6-inch FlexSteel pipe into the existing FM120 bare steel pipeline. NFG states that replacement will\nenhance the reliability and safety of NFG's FM120 Pipeline for the public, its shipper's distribution\nmarkets, storage and local production, and users of the state forest where the pipeline runs. Upon\ncompletion, NFG will continue to provide connectivity for storage and transportation services. The\ninsertion process will greatly reduce the earth disturbance and amount of time required to complete the\nproject as compared to the standard direct bury, or open trench type of construction.\nIL.\nRegulatory Background\nThis special permit application request seeks a special permit (waiver) to use flexible steel pipe in a\ngas transmission pipeline that operates at a maximum allowable operating pressure (MAOP) of 720\npounds per square inch gauge (psig). NFG has requested a special permit (waiver) of the following 49\nCFR 192 sections:\nSection\nSection Title\nDiscussion / Rationale\n192.53\nGeneral\nSub-paragraph (c) does not recognize flexible steel pipe in meeting the\nrequirements of the Subpart.\n192.55\nSteel Pipe\n(a)(1) There is no listed specification for flexible steel pipe.\n(a)(2) Qualification requirements are specific to rigid steel pipe and do\nnot apply to flexible steel.\n192.105\nDesign formula for steel\nThis section does not provide a design formula for flexible steel pipe.\npipe\n192.107\nYield strength (S) for steel\nThis section does not provide a design formula for flexible steel pipe\npipe\nand fittings.\n192.109\nNominal wall thickness (t)\nThis section does not address the steel strip reinforcement used in\nfor steel pipe\nflexible steel pipe.\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 2 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 3>>>\n\n192.111 | Design factor (F) for steel\nThis section does not provide design factors for flexible steel pipe.\npipe\n192.113\nLongitudinal joint factor\nThis section does not apply to flexible steel pipe.\n(E) for steel pipe\n192.144\nQualifying metallic\ncomponents\nThere is no listed specification for the swaged steel connectors to use\nwith the FlexSteel pipe system.\n192.149\nStandard fittings\nThere is no listed specification for the Flexsteel connectors.\n192.150\nPassage of internal\nThere is no need or value in running an ILI tool since the internal\ninspection devices\nwall of the FlexSteel pipe is thermoplastic instead of steel.\n192.327\nCover\nThe existing 12.75-inch diameter steel pipeline is proposed to be\nused as a casing for the new 6-inch FlexSteel pipeline. Given that\nthe existing line was installed in the mid-1950's, there are some areas\nwith less than 30-inches to 36-inches of cover. However, the\nexisting steel pipe, will serve as a casing for the FlexSteel line,\nthereby affording it an additional level of protection from excavation\ndamage and from anticipated wheel loads.\n192.463\nExternal corrosion control:\nThis section envisions steel coated or bare pipe and does not\nCathodic Protection\ncontemplate externally high-density polyethylene (HDPE) lined\nsteel materials. NFG will insert FlexSteel pipe into the existing 12.75-\ninch diameter pipeline, which will be cleaned prior to insertion (See\nSection VIII, Condition 5.a.v for pipeline cleaning procedure). NFG\nwill direct bury and install a cathodic protection test station and anode\nin soil at every FlexSteel fitting outside the 12.75-inch diameter\ncasing.\n192.619\nMaximum allowable\nThis section does not provide a design formula for flexible steel pipe.\noperating pressure: Steel\nor plastic pipelines\nIII. Special Permit Segment and Inspection Area:\nMcKean and Elk Counties, Pennsylvania\nSpecial Permit Segment:\nThis special permit applies to the special permit segment defined as follows using the NFG FM120\nPipeline survey station references:\n• Special permit segment - FM120 Pipeline — (30,624 feet or 5.84 miles) Mile Post 0.0 to 5.84;\nThe special permit segment is defined as 5.84 miles of the FM120 Pipeline which is being replaced\nwith a 6-inch diameter FlexSteel pipe inserted into an existing 12.75-inch diameter pipeline. The special\npermit segment is in McKean and Elk Counties, Pennsylvania. Attachment 1 - FM120 Pipeline\nOverview Map shows the location of the special permit segment.\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 3 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 4>>>\n\nThe special permit segment MAOP will be 720 psig.\nPHMSA grants this special permit based on the findings set forth in the \"Special Permit Analysis and\nFindings\" and \"Final Environmental Assessment and Finding of No Significant Impact\" documents,\nwhich can be read in their entirety in Docket No. PHMSA- 2017-0090 in the Federal Docket\nManagement System (FDMS) located on the internet at www.regulations.gov.\nIV. Conditions:\nPHMSA grants this special permit subject to the following conditions:\n1) NFG must design, operate, and maintain the pipeline in accordance with the following:\na) For purposes of the special permit, the \"special permit segment,\" i.e., the \"Project,\" is\ndefined as the FlexSteel pipe, fittings, monitoring devices, and related facilities to be\ninstalled within the 5.84-mile section of FM120 Pipeline. Other \"new construction\" will\nconsist of those installations outside of the 5.84 miles of the special permit segment and is\nnot included in this special permit.\nb) The pipeline must operate at or below a MAOP of 720 psig. This MAOP has been\nestablished based on the pipeline facilities that the special permit segment is connected to\nLine K, an interstate pipeline that spans between northern Pennsylvania and the Buffalo,\nNew York areas and Line KL, a pipeline that spans between Line K and the FM120\nPipeline.\nThe pipeline must operate at or below a design factor of 0.24 of the stated product burst\nrating of 3,000 psig, which is 48% of the product's 1,500 psig manufacturer pressure\nrating, for all class locations, and road crossings within the special permit segment.\ni) All road crossings must be cased with steel pipe. Any future road crossings using\nFlexSteel pipe must have a minimum of 36-inches cover and must be cased or 49\nCFR Part 192 compliant steel pipe must be installed.\nii) Due to the composite design of FlexSteel pipe, Barlow's formula in 49\nCFR 192.105 cannot be used to determine the pressure rating of this material. Per\nAPI 15S, Second Edition, Section 5.2.5, the maximum pressure rating for a product\nis equal to the product's calculated minimum burst pressure multiplied by a\nmaximum design factor of 0.5. In this case, the 6-inch diameter FlexSteel pipe has\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 4 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 5>>>\n\na minimum burst pressure of 3,000 psig, which results in a maximum pressure\nrating of 1,500 psig.?\nd) NFG must conduct quarterly patrols and instrumented leakage surveys at a maximum of 4-\n½ months, but at least four times each calendar year in accordance with the requirements in\n49 CFR 192.705, 192.706, and 192.935(d)(3) on the special permit segment.\ne) Should a class location increase or expand in length in the special permit segment, NFG\nmust notify PHMSA of the class location changes or of a new high consequence area\n(HCA).\ni) This special permit is not applicable for Class 3 and 4 locations and HCAs or for a\nclass 2 to 3 class location bump as described in 49 CFR 192.611.\nii) The special permit conditions must be reviewed for class location modifications (49\nCFR 192.609) to ensure Code compliance and safety are maintained. If a new\nbuilding intended for human occupancy is identified within 197 feet (1.5 times PIR)\nof the special permit segment and that building causes the Class 1 location to\nbecome a Class 2 location or causes the present Class 2 location to extend in length\nalong the special permit segment, NFG will be required to remove and replace that\nportion of FlexSteel pipe with 49 CFR Part 192-compliant steel line pipe.\nf) NFG must treat the special permit segment as if the entire segment is a covered segment in\nan HCA and must develop and follow an integrity management program in accordance\nwith the requirements of 49 CFR Part 192, Subpart O (except as waived or modified\nherein) applicable to plastic transmission pipelines including the following sections: 49\nCFR 192.901, 192.917(b) through (e), 192.921(a)(2) or (a)(4), 192.935, 192.937 (c)(2) or\n(c)(4), and 192.939(b). This includes, but not limited to, risk assessments, regular\npatrolling, participation in the national one call system, installation of remote controlled\nvalves, and a pressure test re-assessment every seven (7) years, not to exceed 90 months, at\na minimum pressure of 1.5 times MAOP for 24 continuous hours.\ng) NFG must ensure that both its Integrity Management (IM) Procedures and its Operations &\nMaintenance (O&M) Procedures are modified to incorporate the conditions required by\n2 The proposed 6-inch diameter FlexSteel pipe will be 5.60-inch inside diameter and 7.05-inch outside diameter with a rating\n(°F), and maximum installation tension of 30,000 pounds.\nof 1,500 psig, empty weight of 12.9 pounds per foot, maximum pipe operating temperature of 150 degrees Fahrenheit\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation\nPage 5 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 6>>>\n\nthis special permit for the special permit segment. NFG must make these portions of its\nIM Procedures and O&M Procedures available to PHMSA upon request.\n2) General and Design Requirements\na) Branches: NFG must not tap, branch, or split the special permit segment FlexSteel pipe\nwithout the use of the appropriate FlexSteel manufactured fittings for the specified\napplication.\n3) Material and Testing Requirements\na) Pipe Layers: NFG must install line pipe in the special permit segment that is comprised of\nhigh density polyethylene (HDPE) PE4710 inner and outer layers made from natural gas\npipe grade material, which meet the material requirements of API 15S, Second Edition.\nAll FlexSteel components must be manufactured and tested in accordance with API 15S,\nSecond Edition.\nb) Regrind and Rework of Polymeric Materials: Materials used in the manufacture of the pipe\ninstalled within the special permit segment, during construction or in future repairs or\nreplacement, may not contain any regrind or rework material.\nc) Outdoor Pipe Storage: NFG must comply with API 15S, Second Edition requirements for\noutdoor storage and ultraviolet radiation exposure of polyethylene (PE) pipe for all\nFlexSteel pipe materials used in the special permit segment. NFG must document\ncompliance with API 15S, Second Edition in its Material Specifications and O&M\nProcedures. NFG must obtain mechanical and chemical properties test reports that certify\nthe steel by heat used in manufacturing the FlexSteel pipe.\nd) Factory Pressure Testing: All pipe used in the special permit segment must be factory\npressure tested to a minimum of 1.3 times MAOP for a minimum of one (1) hour. NFG\nmust make available pressure test records demonstrating that all special permit segment\npipe was factory pressure tested. Such records must be traceable to all line pipe repair pipe\nor replacement pipe used within the special permit segment and must include: pressure test\nreports, pressure testing parameters (pressure, time, procedure and/or standard number,\ndate, etc. and test acceptance parameters), and pressure testing recorders with current\ncalibration records for pressure test recoding equipment. NFG must provide a certification\nfrom the pipe manufacturer that the tests were completed and that all pipe was visually\nchecked during the pressure tests for leaks. NFG must make available all pressure test\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 6 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 7>>>\n\nrecords to the Director, PHMSA Eastern Region prior to operation of the special permit\nsegment upon request.\ne) Long-Term Integrity: In designing the pipeline, NFG must consider and plan for all\npipeline risk factors, including, but not limited to: pressure and temperature cycling;\nperformance of multilayer composite pipe in subzero temperatures, and repairs under a\nrange of ambient conditions; long term performance of composite material and mechanical\nfittings; cathodic protection of metallic appurtenances; coating performance; long term\nperformance of pipe; risk migration through damage inner pipe wall; and methods for\nassessment of buried or excavated pipe.\ni) NFG must schedule and perform five (5) inspections during which non-destructive\nand destructive testing must be performed on the pipe material after installation.\nNondestructive testing must focus on the composition and degradation of the pipe\nmaterial and destructive testing must include a hydrotest to burst pressure. NFG\nmust perform these inspections and tests at a maximum of 1, 2.5, 5, 7.5 and 10 year\nintervals (not to exceed this timing by 90-days) after installation.\nii) A section of pipe no less than 200 feet must be installed in such a way that\nsimulates the condition of the special permit segment (i.e. cased) in the immediate\nvicinity of the operating pipeline at Milepost 0 on or near NFG's property, see\nAttachment 1- FM120 Pipeline Overview Map. This FlexSteel pipe segment must\nhave 20 feet removed during the intervals defined in (i) to be evaluated, including\ndestructive testing. The results must be made available to the Director, PHMSA\nEastern Region.\n1. Each removed segment must be disassembled, visually, and non-\ndestructively inspected, as appropriate, for any indications of corrosion;\n2. FlexSteel's internal and external HDPE layers must be destructively tested\nper ASTM D638-03 (Standard Test Method for Tensile Properties of\nPlastics) 2003 edition for yield strength, ultimate strength, and elongation.\nThese properties must be evaluated based on the requirements of ASTM\nD2513-12ael (Standard Specification for Polyethylene (PE) Gas Pressure\nPipe, Tubing, and Fittings) April 1, 2012 edition, Section 5.12.2.1\n(Elongation) Table 1, and ASTM D3550-12el (Standard Specification for\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 7 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 8>>>\n\nPolyethylene Plastics Pipe and Fittings Materials) April 1, 2012 edition,\nTable 1 (Yield Strength).\n3.\nFlex Steel's inner core must be destructively tested per ASTM A370-18\nDecember 1, 2018 edition for yield strength, ultimate strength and\nelongation and per ASTM A751-14a October 1, 2014 edition for chemical\ncomposition. These results must be evaluated based on the requirements of\nASTM A109-16 (Standard Specification for Steel, Strip, Carbon (0.25\nMaximum Percent), Cold Rolled) 2016 Edition Table 2 (Chemical\nProperties). The results of the mechanical properties testing shall be per\nthe manufacturer's requirement for as-received steel strip materials. These\nmechanical property values exceed the values listed in ASTM A109-16.\nAcceptance criteria is available for review upon request, but for trade\nsecret reasons, it is requested that the criteria not be listed in the docket\nfolder.\n4. A section of FlexSteel pipe must be burst tested per the requirements of\nAPI 15S, Second Edition, Section 5.2.3.5.\niii) Perform removal, replacement, and installation of pipe and fittings, and other\nactions related to the removal of test segments, in accordance with the requirements\nof this special permit.\niv) NFG must report the results of the inspections and tests to the Director, PHMSA\nEastern Region within 60 days of completion of testing.\n4) Construction Operator Qualifications\na) If the performance of a construction task associated with construction or repair of the\nspecial permit segment could affect the integrity of the segment, NFG must treat that task\nas a \"covered task\" notwithstanding the definition in 49 CFR 192.801(b), and must\nimplement the requirements of 49 CFR Part 192, subpart N. NFG's construction operator\nqualification (COQ) procedures, training program, and qualification tests must include\ndetailed information on all construction-related tasks as a covered task.\nb) NFG must develop and implement a COQ plan that specifically relates to construction\nactivities for the special permit segment. The purpose of the plan must be to ensure\nconstruction personnel and operations personnel are trained. The COQ plan must be\nfollowed throughout the construction phase with respect to the following: pipe inspection,\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 8 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 9>>>\n\nhauling and stringing, appurtenance inspection, field jointing methods, installation of\nappurtenances, pull through of the pipeline, padding and backfilling as required,\nhydrostatic testing, pipe repairs made from hydrostatic testing, dewatering and purging,\nand inspection of work (i.e. trenching, excavating, etc.). These tasks can affect the\nintegrity of the special permit segment and must be treated as \"covered tasks.\" The\nindividuals driving the pipe trucks to the pipeline right-of-way will not need to be COQ\nqualified, unless they are responsible for the pipe unloading.\nc) NFG must also treat in the following special permit segment tasks as covered COQ\n\"covered tasks\", such tasks include: right-of-way soil stability determination, surveying,\nlocating foreign lines, one call notifications, ditching or excavation, cathodic protection\n(CP) system surveys, mitigation, and installation, anomaly evaluations and repairs, right of\nway clean up (including installation of line markers), SCADA control point installation and\nverification, gas quality monitoring, and quality assurance monitoring.\nd) NFG must have FlexSteel personnel on-site when initial pipeline installation is conducted.\ni) NFG must have FlexSteel certified joining personnel onsite installing all FlexSteel\ncouplings.\ne) NFG must make available its COQ plan to the Director, PHMSA Eastern Region 30-days\nprior to beginning construction.\n5) Excavation, Pipe Cover, and Damage Prevention\na) Pipe - Inspection for Damage:\ni) NFG must make available its inspection training and qualification plan to the\nDirector, PHMSA Eastern Region 30 days prior to the start of construction. This\nplan must define the requirements and training necessary to inspect and evaluate\ndamage to FlexSteel pipe and fittings. In addition, NFG must have FlexSteel\nemployees on site during any insertion activities not only to advise on any\nconstruction related activities but to assist in inspection, evaluation, and repair of\nany damage indications, should they be encountered.\nii) NFG must inspect the pipeline during offloading at the storage yard, offloading on\nlocation, during uncoiling, placement into the ditch, backfill, right-of-way grading,\nand clean up.\niii) NFG must certify and document all inspections with date, time, pipeline station,\nand pipe spool number.\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 9 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 10>>>\n\niv) NFG must inspect the leading 25 feet of pull-through pipe for damage, and replace\nany damaged pipe. All indications of pipe damage must be evaluated and replaced\nor repaired as follows:\n(1) Option 1 - Minimal Damage to the Pipe Shield: Gouges or scrapes that\nexceed 0.1181 inches or 3 millimeters (mm) in depth must be repaired in\naccordance with Option 2 or 3 below or replaced with new pipe.\n(2) Option 2 - Moderate Damage to the Pipe Shield with No Steel Strip\nExposed: gouges more than the depth specifications listed above must be\nrepaired with either a pipe clamp or a pipe repair system consisting of\npolyethylene/butyl rubber pipeline tape, heat-activated wrap, or replaced\nwith new pipe. Prior to applying the clamp or wrap, gouges must be\nsmoothed and blended with an appropriate grit sand paper or equivalent\nmaterial. For this repair option to be used the pipe must contain: no visible\nevidence of exposed steel layers, outer sheath damage must be less than six\n(6) square inches, and the outer sheath damage cannot be more than halfway\naround the pipe.\n(3) Option 3 - Extensive Damage to the Pipe Shield: When the steel layer has\nbecome exposed or the degree of outer sheath damage exceeds the\nparameters specified in Option 2 above, the damaged section of the pipe\nmust be cut out and a midline connection installed.\nv) During the pre-installation, NFG must develop procedures for internally cleaning\nthe existing 12.75-inch diameter pipe (future casing pipe) to remove liquids and\ndebris and to inspect the casing pipe for any hazards that could damage the\nFlexSteel pipe during the casing pull through.\nvi) Prior to insertion, each insertion section of the special permit segment must be\npigged with a cleaning pig to verify the cleanness of the section. If any liquids are\nfound as a result of this run, additional cleaning pig runs must be performed until\nno visible liquids are found.\nvii) During the insertion process, the tensile force on the FlexSteel pipe shall be\nmonitored by use of a calibrated dynamometer, calibrated within six (6) months of\nuse. This tensile force shall be limited to 24,000 pounds which is 80% of\nFlexSteel's rating of 30,000 pounds.\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 10 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 11>>>\n\nb) NFG must develop and implement O&M Procedures and/or Construction Specifications to\nremove and replace any FlexSteel pipe with the following conditions:\n1)\nCuts, scrapes, abrasions, or gouges that at any place exceeds the criteria for wall\ndamage defined in Condition 5(a).\nii) Discolorations of the outer HDPE layer that may indicate material degradation or\nlack of homogeneity;\nili) All FlexSteel pipe must be newly produced after the grant of this special permit and\nnot obtained from inventory. The outside HDPE layer is PE 4710 wịth 2% carbon\nblack content, which has a 50-year UV resistance per ASTM D3350.3\niv) Any section of FlexSteel pipe that appears to contain cracking or crazing (may\nrequire laboratory testing to determine any widespread materials issue with the\npipe); and in the event, that crazing is identified, crazing less than 0.07874-inches\n(2 mm) in depth will have no adverse effects on the pipe. Any damage exceeding\n0.07874-inches (2 mm) in depth will require a more detailed assessment to\ndetermine the appropriate mitigative measures, up to and including replacement.4\nv) NFG must not install any FlexSteel pipe above grade (ground).\nc) Other possible signs of material damage or unsoundness must be reviewed by qualified\npersonnel, and if the integrity of the FlexSteel pipe is negatively affected, NFG must\nremove and replace such pipe.\ni) NFG must document its repair and replacement procedures and standards within the\ncomprehensive written specifications or standards required under 49 CFR 192.303\nand the O&M Procedures required in 49 CFR 192.605.\nii) NFG must develop O&M Procedures based upon safe operating conditions, but\nmust hand dig for initial location of the special permit segment pipeline and\nassociated monitoring devices' communication lines. NFG must hand dig\nwhenever excavation operations are within two (2) feet of the pipeline and\nassociated monitoring devices' communication lines.\n3 NFG and FlexSteel do not believe discolorations will be an issue for this application.\n4 NFG and FlexSteel believe crazing and cracking will be unlikely for this project.\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 11 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 12>>>\n\niii) NFG must prepare and follow a damage prevention program in accordance with 49\nCFR 192.614. NFG must make this program part of its O&M Procedures prior to\nplacing the special permit segment in natural gas service.\nd) NFG must ensure that the special permit segment will comply with the requirements in 49\nCFR Part 192, except as waived or modified herein as listed in Section II - Regulatory\nBackground.\n6) Corrosion Control\na) NFG must apply cathodic protection (CP) on all buried FlexSteel pipe components, and\njoints within the special permit segment in accordance with 49 CFR Part 192 (except as\nwaived or modified herein). Electrical conductivity of swaged joints to inner pipe layer\nmust be tested.\ni) Each FlexSteel fitting must be installed with an anode and CP test station. These\nfittings are electrically conductive with the FlexSteel pipe inner steel core.\nb) Test stations: NFG must install CP test stations at each metallic connector.\nc) NFG must perform external corrosion control monitoring on each buried metallic fitting in\naccordance with 49 CFR 192.465. NFG must perform CP monitoring at least once each\ncalendar year, not exceeding 15 months. Corrosion control monitoring of the buried\nmetallic fittings by a sampling basis is not permitted.\ni Each stainless steel and carbon steel FlexSteel fitting must be installed with a test\nstation and anode, coated and direct buried.\nd) NFG must determine the native structure-to-electrolyte potential for each buried metallic\nfitting prior to energizing the CP system.\ne) NFG must seal the 12.75-inch casing ends to prevent water and other debris from entering\nthe casing annulus.\nf) NFG must ensure that no 12.75-inch casing end, where natural gas can leak or migrate to\nthe soil surface, is within the 6-inch FlexSteel pipe PIR (minimum of 131 feet) of a\ndwelling for human occupancy for the life of the special permit.\ng) NFG must develop and implement Construction and O&M Procedures to identify non-\nisolation areas and maintain electrical isolation of the FlexSteel pipe inner steel core from\ncontact with the steel casing pipe and from water entering the inner steel core.\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 12 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 13>>>\n\n7) Pressure and Temperature Control and Monitoring\na) NFG must install an annulus monitoring system (Condition 7(d) below) that will provide\ncontinuous integrity monitoring of the external HDPE layer. If a holiday is present on the\n. external layer, this system will detect this defect.\nb) Over-pressure Protection: NFG must install over-pressure protection equipment necessary\nto keep the pipeline pressure from exceeding 720 psig plus allowable build-up at any time.\nAllowable build ups are those conditions which occur due to anomalous conditions outside\nof the special permit segment. Occurrences resulting in pressures exceeding 720 psig plus\nallowable build-up of MAOP plus 4%, must be reported to the Director of PHMSA Eastern\nRegion within 24 hours or the next business day of the occurrence for their review.\nc) Pressure Monitoring: NFG must monitor operating pressures by the installation of pressure\ntransmitters and switches in the piping system that report to the facility's SCADA system.\nNFG must monitor the special permit segment with continuous and redundant pressure\ntransmitters and switches. NFG must provide a means to inform operator personnel\nperforming work on the pipeline of the pressure on the line.\nd) Annulus Monitoring: NFG must install an annulus monitoring system that will provide\ncontinuous integrity monitoring of the external HDPE layer. If a holiday is present on the\nexternal layer, this system will detect this defect.\nNFG must continuously monitor through SCADA the pressure of the annulus space\nbetween the FlexSteel pipe HDPE layers along the \"entire special permit segment.\"\nThese pressure monitoring transmitters and pressure vents must be located at valve\nsettings at Mile Post 0 and Mile Post 1.2, see Attachment 1 - FM120 Pipeline\nOverview Map.\nii) The annulus between inside liner and outer jacket HDPE materials is used to\nmonitor pipe integrity. This annulus is a pressure containing capable structure that\nis designed to contain pressure up to 30 psig. 1/8-inch female (national pipe thread)\nNPT outlets on the end fittings will be outfitted with the necessary tubing to attach\npressure transmitters that must be incorporated into SCADA monitoring. With\npermeated gasses permitted to build to a predetermined level (15 to 20 psig),\ntransmitters will be configured to alarm on indications of high or low pressure\noutside of the established acceptable range. Continuous pressure readings within\nacceptable ranges provide real time indication that several key integrity features are\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 13 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 14>>>\n\nfunctioning as designed. Positive pressure indicates the outer jacket material is\nintact (holiday free), demonstrating a \"perfect coating\", thus external corrosion\ncannot occur. It indicates that the HDPE liner material is intact and containing bore\ngas pressure as intended. Any breach of the liner will expose the outer jacket to\nbore pressure, resulting in a loss in pressure indicated by the \"real time\" annulus\nmonitoring. This monitoring will alert NFG that third party damage or liner failure\nmay have occurred, allowing prompt response for further investigation. NFG will\nuse this monitoring capability and monitor this annular pressure with a SCADA\nsystem on a continuous 24-hour basis.\niii) The FlexSteel fittings must be designed to allow the annulus of each segment of\npipe to be common with each other, so that monitoring of the annular space can be\nconducted at one end of the system.\niv) A pressure relief valve with a 20 psig set point must be installed with annulus\nmonitoring equipment to maintain the 15 to 20 psig pressure range. This relief and\nthe associated annulus monitoring equipment must be located within fenced in\nlocations at Mile Posts 0 and 1.2.\ne) Gas Temperature: NFG must continuously monitor natural gas temperature at the discharge\nof NFG's Wellendorf Compressor Station, see Attachment 1 - FM120 Pipeline Overview\nMap, in order that the pipeline is not exposed to temperatures exceeding 150 degrees\nFahrenheit (°F). If the FlexSteel pipe is exposed to temperatures exceeding 150 °F, the\nspecial permit segment pipeline must be shut down, pressure reduced to a maximum of\n20% below the current operating pressure, and the Director, PHMSA Eastern Region must\nbe contacted within two (2) working days of the detection for their review.\nf) SCADA and Shut-In:\ni) NFG must continuously monitor the special permit segment with a SCADA\nsystem. Remote controlled valves must be installed within the vicinity of Milepost\n0 and Milepost 1.2.\nii) If communication is lost for over three (3) hours, NFG must have personnel onsite\nto continue operations and monitoring of the special permit segment.\niii) NFG must document SCADA operating procedures and Control Room\nManagement Procedures (49 CFR 192.631), within the O&M Procedures for the\nspecial permit segment.\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 14 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 15>>>\n\n8) Construction and Operations\na) Tools and Equipment: NFG must have tools and fittings available either by stocking such\nor from a local vendor such that it can respond within a reasonable time to operational\nmaintenance and emergency repairs (the number and types must be detailed in the O&M\nProcedures):\nAn inventory of tools and materials must be indicated in the O&M Procedures for\nmaintenance and emergency repairs.\nii) NFG must have available either by stocking such or from a local vendor\nappropriate tools and fittings to repair and replace appurtenances and piping within\nthe special permit segment.\niii) NFG must maintain a supply of FlexSteel pipe at NFG's project and/or operational\nmaintenance yards for the special permit segment.\niv) Construction Specifications: NFG must develop construction specifications for all\nconstruction phases of the special permit segment. These construction\nspecifications must be made available to the Director, PHMSA Eastern Region, 30-\ndays prior to beginning construction of the special permit segment pipeline.\nb) Inspection criteria: NFG must develop inspection criteria for construction procedures and\ndocument them within the O&M Procedures. The inspection criteria must meet the\nrequirements of these special permit conditions and 49 CFR Part 192 (except as waived or\nmodified herein). These inspection criteria must be made available to the Director,\nPHMSA Eastern Region, 30-days prior to beginning construction of the special permit\nsegment pipeline.\nc) Repair criteria: NFG must develop pipe repair criteria and document them within the O&M\nProcedures. Repair criteria must be submitted to the Director, PHMSA Eastern Region,\n30-days prior to beginning construction of the special permit segment pipeline.\nd) Hydrostatic test: Prior to NFG putting the pipe in service, the pipe, connections, and\nappurtenances must be field hydrostatically tested at a pressure of 1.5 times the MAOP of\n720 psig (minimum test pressure of 1080 psig) for a minimum of 24 hours with recording\ncharts (pressure chart, temperature chart, dead weights and log, and calibration records of\nequipment, calibrated within 30 days of test), the results of which must be made available\nto the Director, PHMSA Eastern Region for review, including determination parameters of\nSpecial Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 15 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 16>>>\n\nan acceptable test. NFG must compensate for temperature and elevation variations and\nsuch compensation must be documented on test records.\ne) Leakage detection surveys: NFG must conduct leakage detection surveys of the entire\nspecial permit segment four (4) times per calendar year at a minimum, not to exceed 4-½\nmonths between surveys, utilizing instrumented leak detection equipment capable of parts\nper million (ppm) detection. NFG must repair all leaks as they are found, and notify the\nDirector, PHMSA Eastern Region of any leaks found within two (2) business days. Leak\ntesting procedures, equipment, and scheduling must be documented within the O&M\nProcedures. The first survey must be performed within 48 hours of commencement of\npipeline operations with natural gas.\nf) As defined in Condition 1, any new construction outside the special permit segment must\nconform to 49 CFR 192.327 - Cover.\n• NFG must conform to the depth of cover requirements in 49 CFR 192.327 for any\nnew construction outside of the special permit segment.\nii) Based upon available depth of cover information, the pipe located at the northern\nend (the Class 2 section of line) of the special permit segment has depths of cover\nmeeting 49 CFR 192.327, while the data available in the Class 1 section indicates\nvarying depths, all of which may not meet 49 CFR 192.327 requirements\ndepending on soil conditions (i.e. Class 1 locations in consolidated rock may be\ninstalled at a depth of cover of 18 inches per 49 CFR 192.327 as opposed to an\ninstallation depth of cover of 30 inches in normal soil). In addition, two known\nexposures of the existing line (one at a stream crossing at Milepost 4.45 and one\nupland exposure at the southern terminus of the project) exist. The pipe at these\nlocations must be removed and the FlexSteel replacement pipe will be direct buried\nin these locations to a depth of cover meeting 49 CFR 192.327 requirements. All\npipe locations with cover less than 24-inches must have additional preventive and\n\" A primary objective of NFG's special permit request was to capitalize on the opportunity to perform the construction via\ninstallation was before Part 192 was developed, and there are locations that do not meet depth of cover requirements.\nSpecial Permit: PHMSA-2017-0090 — National Fuel Gas Supply Corporation Page 16 of 26\nSpecial Permit Conditions for FM120 pipeline to use FlexSteel Pipe\n\n<<<PAGE 17>>>\n\nmitigative measures such as additional pipeline markers, lowering the pipe, adding\ncover, or installing subsurface concrete safety barriers.®\niii) Due to the insertion method, periodic bell holes will be dug and sections of the\nexisting pipeline will be removed to facilitate the installation process. In these\nareas, the FlexSteel coupler fittings will be direct buried, along with the adjacent\nFlexSteel pipe. To minimize environmental impacts, the bell holes will be kept to a\nminimum length that will allow for the safe installation of the FlexSteel pipe. The\nexpected length of the bell holes is anticipated to be approximately 30 f","truncated":true,"body_characters":60060}